Court entered order finding Respondent mother unfit and terminating her parental rights. The time to complain of alleged errors in the neglect proceeding passed long before Respondent filed her notice of appeal, as she failed to file a notice of appeal within 30 days of the dispositional order. Even where a respondent alleges ineffective assistance of counsel during adjudicatory phase of proceedings, appellate court lacks jurisdiction over such claims in an appeal from an order terminating parental rights. The only exception to this rule is where the court lacks personal jurisdiction over a defaulted parent due to, for example, improper service. Adjudicatory and dispositional orders are not within the procedural progression of orders terminating parental rights. (JORGENSEN and HUDSON, concurring.)
Illinois Appellate Court
Civil Court
Termination of Parental Rights